Larsen 333 Petition

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Erick F. Larsen

262 W. Linden Ave. # C

Burbank, LA, Ca 91502

818-732-0330

ErickLarsen@Outlook.com

July 16, 2015

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., 

SE Washington, DC 20590

Re: Erick F. Larsen’s Request (Petition) for Exemption from Certain Regulations per Section 

333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) 

and 14 C.F.R. Part 11, Erick F. Larsen (Larsen, Petitioner, or Operator) hereby applies for an 

exemption from the listed Federal Aviation Regulations (FARs) to allow business use 

(commercial operation) of his Unoccupied (unmanned) Aerial System (UAS), so long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

I. INTRODUCTION

Petitioner, Erick F. Larsen, is a United States born citizen, with the following contact 

information, residing at:

262 W. Linden Ave. # C

Burbank, Los Angeles Co, Ca 91502

818-732-0330

ErickLarsen@Outlook.com

Petitioner, Larsen, has been building and operating model aircraft for more than fifty (50) 

years. Petitioner currently maintains a duly issued US Passport and a Driver’s License issued 

by the California Department of Motor Vehicles (DMV). Moreover, as a former IT Airport 

Systems Program Manager upon behalf of Los Angeles World Airports (LAWA), the operator 

of the Los Angeles International Airport (LAX), Petitioner, Larsen, has been cleared 

(background checked) to work in all of the most secure and sterile areas within and on the 

surrounding airfield of the Tom Bradley International Terminal (TIBIT) of LAX including 

within all critical IT Data Rooms of LAWA and of the Federal Inspection Service Areas (FIS) of 

the US Customs and Border Protection (CBP) which is part of the US Department of 
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Homeland Security (DHS). A copy of petitioner’s LAX/CBP/FIS badge is confidentially 

attached.

In addition, Petitioner successfully underwent a distinct background investigation in 

October of 2013 by the State of California in order to become a Covered California Certified 

Enrollment Counselor (CEC) #1969, which is a matter of public record.

Small business is the backbone of America. Through years of UAS hobbyist experience, 

petitioner has developed numerous diverse prospective clients in need of safe and lawful 

commercial UAS aerial data collection (ADC) services. A small UAS business operated by 

petitioner will provide new jobs and an increased level of safety to clients currently in need 

of UAS ADC commercial services. Existing FAA UAS policy bars Petitioner from providing UAS 

ADC commercial services in the absence of the requested exemption. 

Petitioner seeks to operate UAS to conduct aerial data collection (ADC) which includes any 

remote sensing and measuring by an instrument(s) aboard the Unoccupied (Unmanned) 

Aircraft (UA). Examples include imagery (photography, video, infrared, etc.), electronic 

measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate 

measurement, etc.), or any other gathering of data by instruments aboard the UA.

In particular Petitioner seeks authorization to conduct commercial UAS remote ADC, 

mapping, surveying, photography, filming, demonstrations, training, surveying, measuring, 

and inspections of (or for):

1.) Construction, architectural, engineering, insurance, risk management, security, real 

estate, resort, golf, cemetery, entertainment, sports, utility, energy (oil, gas, solar, wind, 

& electric), hydro (water), transportation (port, rail, truck, & bus), mining, bridge, 

telecommunications, agriculture (farming, ranching, & growing) flare stack, platform, 

tower, pole, and pipeline infrastructure, structures, sites, systems, features and 

operations; and,

2.) Environmental, scientific, conservation, climate change, natural 

resource, wildlife, oceanographic, forestry, weather, search & rescue, emergency 

services, humanitarian relief, public & private entity support, assistance and monitoring 

of infrastructure, structures, sites, systems, features, and operations; and,

3.) Research, education, training, development, testing, certification, and validation of 

safe and lawful commercial, hobby, and recreational UAS curriculum, education, and 

safe flight training, demonstrations, and events involving UAS design, manufacture, 

assembly, purchase, sale, maintenance, repair, inspection, safe operation, record 

keeping, and required FAA documentation.

Hereinafter, 1, 2, and 3, above, referred to as petitioner’s "proposed operations".
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In support of his application, petitioner confidentially submits his proprietary Flight 

Operations Manual (FOM) and a flight manual for his DJI Phantom 2 Vision+ (P2v). 

Petitioner’s P2v UAS has been duly registered with the FAA which has assigned registration 

number N558WC.

Specific Regulations for which an exemption is sought:

14 CFR 61.113 (a) 

14 CFR 91.7 (a) 

14 CFR 91.119 (b) & (c) 

14 CPR 91. 121

14 CFR 91.151 (a) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1)

14 CPR 409 (a) (1) & (2)

14 CFR 417 (a) & (b)

II. PETITIONER’S PROPOSED OPERATIONS DO NOT CREATE SIGNIFICANT 

HAZARDS

The P2v UAS utilized by Petitioner is an electric multi-rotor craft, weighing less than 55 lbs. 

including ADC payload. It operates at a speed of no more than 100 mph (87 knots) and has 

the capability to hover, and/or move in a vertical and horizontal plane simultaneously. It will 

only be operated as visual line of sight (VLOS), remain under 400 ft. above ground level 

(AGL), and will operate only over private or controlled access property with permission from 

the owner/controller of the property or authorized representative.

During petitioner’s proposed operations the site will be secured and non-participants will be 

kept at least 500 feet away from the operation unless barriers or structures are present that 

sufficiently protect non-participants in the event of an accident or loss of control.

Petitioner has drafted, and submits confidentially, his Flight Operations Manual (FOM) 

which discusses safety considerations, training, general operating procedures, 

specifications, inspection, maintenance, setup of the UAS, and other proprietary procedures 

for the proposed UAS operations. 

III. PETITIONER LARSEN'S PROPOSED OPERATIONS ARE IN THE PUBLIC 

INTEREST

The FAA has issued a Grant of Exemption to FalconSkyCam for operations that are 

substantially similar to those proposed herein. Docket No. FAA-2014-0884 (March 6, 2015). 

In issuing the Grant, the FAA noted that "[t]he enhanced safety and reduced environmental 

impact achieved using a UAS with the specifications described by the petitioner and carrying 

no passengers or crew, rather than a manned aircraft of significantly greater proportions, 

carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS 

operation enabled by this exemption is in the public interest."
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Accordingly, Petitioner respectfully requests that the FAA grant the requested exemption 

summarily and without delay.

IV. EQUIVALENT LEVEL OF SAFETY

Petitioner proposes that his P2v UAS requested exemption with the characteristics and as 

operated with the limitations listed below, provide for at least an equivalent or even higher 

level of safety to operations under the current regulatory framework.

These limitations and conditions to which Petitioner agrees to be bound when conducting 

commercial operations under an FAA issued exemption include:

1.) The P2v UAS utilized by Petitioner will weigh Less than 55 lbs, operate at a speed of 

no more than 100 mph (87 knots), and will remain under 400 ft. (AGL).

2.) Flights will be operated only during daylight hours, only in visual meteorological 

conditions, and only within visual line of sight (VLOS) of the pilot in command (PIC) 

of the UAS.

3.) All operations will utilize a visual observer (VO) in addition to the pilot in command 

(PIC).

4.) Maximum total flight time for each operational flight will be approximately 30 

minutes, or when the Low Battery warning activates.

V. EXEMPTIONS REQUESTED

14 C.F.R. § 61.113 (a) and (b): Private, Recreational, or Sport vs. Commercial Pilot 

Certificates

Sections 61.113 (a) and (b) prohibit private, recreational, or sport certified pilots from 

operating a traditional aircraft for compensation or hire. Petitioner proposes that his PIC 

will have at least a private, recreational, or sport pilot’s certificate, and a current FAA 

medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal government. Petitioner’s PIC will also 

meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the 

PIC is rated on his or her pilot certificate. 

Petitioner will not permit any PIC to operate unless the PIC demonstratesthe ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under 

petitioner’s exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight 

hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Flights for 

the purposes of training the petitioner’s PICs and VOs (training, proficiency, and experiencebuilding) and determining the PIC’s ability to safely operate the UAS in a manner consistent 

with how the UAS will be operated under petitioner’s exemption are requested by 

petitioner to be allowed under the terms of this exemption. 
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Petitioner further proposes that such PIC and VO training operations will only be conducted 

during dedicated training sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations will be considered nonparticipants, and 

the PIC will operate the UA with appropriate distance from nonparticipants in accordance 

with 14 CFR § 91.119.

Based upon the above and for the reasons set forth in the FAA's grant of an exemption to 

Astraeus Aerial, Petitioner does not believe a commercial pilot certificate is necessary for 

the operations it intends to conduct. See, e.g., In the matter of the petition of Astraeus 

Aerial, Exemption No. 11062 (issued Sept. 25, 2014). For those reasons, Petitioner requests 

an exemption from 14 C.F.R. § 61.113 (a) and (b).

As the petitioner’s preferred alternative exemption to the above PIC pilot rating and 

certification requirements Petitioner respectfully requests an exemption from the manned 

aircraft flight proficiency sport pilot certificate requirements of 14 CFR § 91.119; §61.311; 

and §61.313 (and any similar provisions as best determined by the FAA). Specifically, 

petitioner requests that his PIC be exempted only from having to actually pilot a full sized 

traditional aircraft as an essential part of UAS PIC qualifications, certification, and training to 

become FAA certified as a P2v UAS PIC for the proposed operations.

Currently to obtain a sport pilot certification about 25 hours of actual manned aircraft pilot 

flying experience with an instructor is required. Five hours of flying solo. Fifteen hours of 

ground instruction. And, about 25 hours of home study. Costs vary by location. Petitioner 

reasonably estimates his costs would be approximately $6,500 to obtain a sport pilot

certification.

Having to pilot a large, manned, traditional, aircraft as a condition to FAA authorization to 

operate petitioner’s P2v UAS, respectfully, seems to be unnecessarily unsafe, hazardous, 

and does not relate to a UAS PIC’s fitness or skill set reasonably required to safely and 

competently operate petitioner’s P2v UAS. Instead, Petitioner respectfully requests that his 

PIC be required to meet all of the exact same aircraft ground school training and testing as 

is currently required to obtain a recreational or sport pilot (sport pilot) certification.

It is understood that all UAS operators, both recreational and commercial, need to have a 

clear understanding of the National Airspace System (NAS) and of safe and competent UAS 

operations. That knowledge can be verified by operator attending FAA private pilot ground 

instruction and by passing FAA Private Pilot written examination for sport pilot or above and 

logged UAS training. That should be reasonably safe and sufficient. Why would an operator 

need flight experience as a pilot of a full sized manned aircraft to operate a 3 pound UAS 

P2v quad-copter?

Requiring petitioner to hire a PIC (who may have no skills in flying a small UAS) or having to 

bear the time and expense of completing pilot flight proficiency training in a manned
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aircraft, is an unfair burden to place on petitioner, who is faced with overwhelming 

competition from unauthorized operators who openly ignore FAA commercial UAS policy. 

The standard PIC manned aircraft flight proficiency requirements for a small UAS operator 

which have been applied to past applicants for exemptions is unfair, unnecessary and 

excessively unsafe.

Moreover, in further support of petitioner’s request for exemption, petitioner proposes 

that his PIC shall undergo the exact same background check and meet the same citizenship 

or permanent residency requirements as are currently required for FAA sport pilot 

certification. Petitioner maintains that a greater level of safety will be maintained in the

NAS and far less risk of personal injury, damage, and danger to the public and to petitioner’s 

PIC will result by exempting petitioner’s PIC from unnecessarily having to personally pilot a 

large, traditional, manned aircraft in the NAS as an essential part of the FAA required P2v 

UAS pilot qualifications, certification, and training.

In addition, petitioner proposes that his PIC shall undergo thirty (30) hours of logged UAS 

flight training, fifteen (15) hours of which shall be on the particular P2v UAS to be used in 

the proposed operations. As part of petitioner’s PIC training the PIC will be required to 

safely conduct at least five (5) takeoffs and five (5) landings with the particular UAS to be 

used by the PIC in petitioner’s proposed operations. 

In N 8900.227 National Policy, “Unmanned Aircraft Systems (UAS) Operational Approval” 

the FAA in pertinent part has said (emphasis added):

a. “UAS Pilot Qualifications. The FAA is focused on ensuring that UAS pilots have an 

appropriate level of understanding of 14 CFR applicable to the airspace where UAS 

operate. UAS pilots are responsible for controlling their aircraft to the same standards as 

the pilot of a manned aircraft. Civil UAS pilots may be required to have instruction by an 

FAA-certificated flight instructor.

. . . .

(2) PIC Rating Requirements. Rating requirements for the UAS PIC depend on the type 

of operation conducted; they fall into two categories:

 Operations that require at least a private pilot certificate or FAA-recognized equivalent, or

 Operations that do not require at least a private pilot certificate or FAA-recognized 

equivalent.

(a) The requirement for the PIC to hold a pilot certificate or FAA-recognized equivalent 

is based on various factors including:

 The location of the planned operations,

 The mission profile,

 The size of the aircraft, and

 Whether or not the operation is conducted within or beyond visual line-of-sight.
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(b) The PIC must hold, at a minimum, an FAA private pilot certificate or FAA-recognized 

equivalent for all operations listed below:

 Flight in Class A, B, C, D, E, and G (400 feet above ground level (AGL)) airspace.

 IFR (must have instrument rating) operations.

 Night operations.

 At joint use or public airfields.

 Requiring a chase aircraft.

 At any time the FAA has determined the need, based on the UAS characteristics, mission 

profile, or other operational parameters.

(c) Operations without a pilot certificate may be allowed when all of the following 

conditions are met:

 The PIC has successfully completed, at a minimum, FAA private pilot ground 

instruction and passed the FAA Private Pilot written examination or FAA-recognized 

equivalents. (Airman Test Reports are valid for the 24 calendar-month period preceding the 

month the exam was completed, at which time the instruction and written examination 

must be repeated.)

 Operations are during daylight hours.

 The operation is conducted in a sparsely populated location.

 Operations are approved and conducted solely within visual line-of-sight in Class G 

airspace.

 Visual line-of-sight operations are conducted no further than 1⁄2 NM laterally from the 

UAS pilot and at an altitude of no more than 400 feet AGL at all times. Refer to 

Appendix A for the visual line-of-sight definition.

 Operations are conducted no closer than 5 NM from any FAA-designated airport or 

heliport other than the airport from which the aircraft is operating.

 The operation is conducted from a privately owned airfield, military installation, or offairport location.

(3) PIC Recent Flight Experience (Currency). The proponent must provide documentation 

showing the pilots maintain an appropriate level of recent pilot experience in the UAS 

being operated, or in an FAA-certified simulator. At a minimum, the PIC must conduct 

three takeoffs (launch) and three landings (recovery) in the specific UAS within the 

previous 90 days (excluding pilots who do not conduct launch/recovery during 

normal/emergency operations); or as prescribed by the proponent’s accepted recurrent 

training and currency program.”

Petitioner proposes in this petition for exemption (and operating documents) to restrict his 

proposed P2v UAS operations to include:

 The PIC has successfully completed, at a minimum, FAA sport pilot ground school 

instruction and passed the FAA Sport Pilot written examination (and background 

checks) or FAA-recognized equivalents, and holds a current FAA medical certificate or

a valid US Driver's License. 

 P2v UAS operations only during daylight hours.
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 P2v UAS operations only in sparsely populated locations.

 P2v UAS operations to be conducted solely within visual line-of-sight in Class G 

airspace.

 P2v UAS Visual line-of-sight operations to be conducted no further than 1⁄2 NM 

laterally from the UAS pilot and at an altitude of no more than 400 feet AGL at all 

times. P2v UAS operations will be conducted no closer than 5 NM from any FAAdesignated airport or heliport other than the airport from which the UAS aircraft is 

operating.

Under the circumstances presented in this petition for exemption, petitioner respectfully 

submits that it is without basis in law and unreasonable, arbitrary, and capricious for the 

FAA to require petitioner’s PIC to be compelled to first pilot a large, traditional, manned 

aircraft as an essential part of FAA required UAS PIC qualifications, certification, and

training. 

Petitioner further respectfully submits that the FAA requirement of having to first pilot a 

large, traditional, manned aircraft as an essential part of FAA required UAS PIC

qualifications, certification, and training violates the provisions of the Americans with 

Disabilities Act of 1990 (ADA), 42 USC §12101 et seq. This piloting of full size manned 

aircraft in the NAS, FAA UAS PIC training requirement also prevents or discourages 

petitioner from hiring perfectly competent, skilled, and able UAS PICs to serve as PICs, who 

would otherwise be equally, or even superiorly, qualified to operate petitioner’s P2v UAS. 

For all of these reasons, Petitioner respectfully requests that this very limited alternative 

exemption from 14 C.F.R. § 61.113 (a) and (b) be granted for the proposed operations as 

FAA-recognized equivalent UAS PIC certification, in the public interest.

14 C.F.R. § 91.7 (a): Civil Aircraft Airworthiness

Section 91.7 prohibits operation of an unairworthy aircraft, and places responsibility for 

airworthiness determinations on the PIC. The UAS will not have an airworthiness certificate, 

and there is no FAA regulatory standard for determining airworthiness of the UAS. 

Additionally, Petitioner's operating documents, including FOM, set forth inspection and

maintenance procedures to ensure airworthiness. For these reasons, and in accordance 

with the FAA's grant of an exemption from section 91.7 to Total Safety U.S., Inc., Petitioner 

requests an exemption from 14 CFR. § 91.7(a). See, e.g., In the matter of the petition of 

Total Safety U.S., Inc., Exemption No. 11156 (issued Jan. 29, 2015).

14 C.F.R. §91.119 (b) and (c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (b) 

prohibits aircraft in congested areas from flying less than 1,000 feet above the highest 

obstacle within a horizontal radius of 2,000 feet of the aircraft. To the extent that 

Petitioner’s proposed operations would be considered to be in "congested areas," 

Petitioner's operational procedures, including FOM, and the size, weight and speed of the 
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P2v UAS, provide an equivalent level of safety such that the proposed operations at lower 

altitudes should be allowed.

As described in his Flight Operations Manual (FOM), Petitioner will establish a 500' 

buffer/sterile area for its operations that will exclude personnel not associated with the 

operations. Petitioner will also exercise additional control over the sterile area as needed, 

as set forth in the FOM. Consequently, Petitioner believes these procedures will reduce or 

eliminate any potential adverse impacts to safety for operations in congested areas. 

Petitioner therefore requests an exemption from 14 CFR § 91.119(b).

Section 91.119 (c) prohibits operations in other than congested areas below 500 feet above 

the surface, or closer than 500 feet to any person, vessel, vehicle or structure. Since this 

exemption is for a UAS that flies similarly to a helicopter and requests authority to operate 

at altitudes up to 400 AGL, an exemption may be needed to allow such proposed 

operations.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as 

well as the location where it is operated. As discussed above, Petitioner’s FOM provides for 

establishment of a sterile area, including safety buffers of 500 feet for personnel not 

associated with the operation. Petitioner therefore requests an exemption from Section 

91.119(c) for all authorized personnel associated with the proposed operations.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain a cruising altitude by 

reference to an altimeter that is set "... to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the UAS may not have a 

barometric altimeter, but instead a constant GPS altitude read out, an exemption is 

requested.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel 

to fly to the first point of intended landing, and, assuming normal cruising speed - (1) During 

the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 

45 minutes."

Maximum total flight time for each of the proposed operations will be no more than 30 

minutes. Flights will be safely landed when the battery falls below its nominal voltage, 

should that occur prior to completion of the operation. The petitioner’s P2v UAS has a 

constant battery voltage display and a Low Voltage LED Warning which alerts when the 

battery reaches pre-determined levels. This battery level would be more than adequate to
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return the UAS to its planned landing zone from anywhere in its limited operating area 

when the Low Voltage Warning alerts.

For these reasons, Petitioner requests an exemption from 14 C.F.R. § 91.151 (a). Similar 

exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner "shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter ...," and others shall inspect or maintain the aircraft in 

compliance with Part 43.

As provided in petitioner’s FOM, the operator and the PIC will ensure that the UAS is in 

working order prior to initiating each flight, and the operator will perform required 

maintenance and inspections, and keep a log of any maintenance performed.

VI.REGULATIONS FOR WHICH EXEMPTIONS ARE UNNECESSARY

The Federal Aviation Administration (FAA) has issued numerous prior exemptions for many 

different types of UAS operations. In those exemptions, the agency noted that exemptions 

from certain regulations were not necessary, due to "the size, weight, speed and limited 

operating area associated with [the UAS] and its operation."

Based upon the FAA's guidance and the fact that petitioner’s UAS is even smaller and slower 

than many of those UAS in previously issued exemptions, Petitioner believes exemptions 

from the following regulations are not necessary:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates. 

14 C.F.R. § 45.23 (b): Marking of the Aircraft.

14 C.F.R. §91.7(b): Civil aircraft airworthiness. 

14 C.F.R. §91.109: Flight instruction.

Petitioner also believes that an exemption from 14 C.F.R. § 91.103: Preflight Action is not 

necessary. This regulation requires each pilot in command to take certain actions before 

flight to insure the safety of flight. An FAA approved rotorcraft flight manual will not be 

provided for the aircraft. An equivalent level of safety will be provided as set forth in the 

FOM and operating documents submitted as part of this request.

The FAA has previously found that adherence to procedures contained in an applicant's 

operating documents demonstrate compliance with § 91.103, and therefore an exemption 
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from the regulation was not necessary. See, e.g., In the matter of the petition of Total 

Safety U.S., Inc., Exemption No. 11156 (issued Jan. 29, 2015).

As detailed in his operating documents, petitioner's PIC will take all actions including 

reviewing weather, flight battery requirements, landing and takeoff clearance distances and 

aircraft performance data before initiation of flight to ensure the safety of the flight. 

Consequently, in light of this agency's prior finding in Total Safety U.S., Inc., Petitioner does 

not believe an exemption from 14 C.F.R. § 91.103 is necessary. 

If it is determined that the petitioner does require exemptions from any of the above 

provisions from which he has herein stated that he believes no exemption is required: 

Petitioner requests that such exemptions be granted upon the basis of all that he has stated 

in this petition.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R. § 61.113 (a) and (b); 91.7 (a); 91.119 (b) and (c); 91.121; 91.151 (a); 

91.405 (a); 91.407 (a) (1); 91.409 (a) (1) & (2) and 91.417 (a) & (b) to conduct 

aerial data collection (ADC) which includes any remote sensing and measuring by 

an instrument(s) aboard the Unoccupied (Unmanned) Aircraft (UA). Examples 

include imagery (photography, video, infrared, etc.), electronic measurement 

(precision surveying, RF analysis, etc.), chemical measurement (particulate 

measurement, etc.), or any other gathering of data by instruments aboard the 

UA.

Approval of exemptions allowing commercial operations of UAS for these 

purposes will enhance safety by reducing risk. Conventional means for 

performing these assessments require either physically climbing or scaling 

structures, poles or towers, using ropes to scale or rappel up or down poles, 

towers or structures, using high-reach man lifts to access the towers, poles, sites, 

or structures (limited reach), or by using conventional helicopters or traditional 

aircraft operating at extremely low altitudes over the subject structure, pole, 

site, or tower being examined. These conventional means all pose high risks to 

persons and property, including many actual human deaths each year.

In contrast, a UAS weighing less than 55 lbs. and powered by batteries, 

eliminates virtually all of that risk given the reduced mass and lack of 

combustible fuel carried on board. The UAS is carried by hand to the proposed 

operations site and not flown. The UAS carries no passengers or crew and, 

therefore, will not expose them to the risks associated with traditional manned 

aircraft flights; ground based aerial lift (bucket truck) operations, or manual 

climbing, scaling, and inspection operations.
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The proposed operations of this small P2v UAS, weighing less than 55 lbs., 

conducted in the strict conditions outlined in this petition, will provide an 

equivalent level of safety supporting the grant of the exemptions requested, 

including exempting Petitioner from the requirements of Part 21 and allowing 

commercial UAS operations. These lightweight aircraft operate at slow speeds, 

and close to the ground, and, as a result, are far safer than the conventional 

alternatives.

Privacy

All of the proposed operations, UAS flights, will occur only over private or 

controlled access property with permission from the owner/controller of the 

property or authorized representative. Petitioner’s proposed operations will be 

conducted in accordance with all applicable laws and regulations governing 

privacy at the venue of the flight operation.

VII. CONCLUSION

Petitioner has requested to use a P2v UAS for aerial data collection (ADC). The FAA has 

issued grants of exemption in circumstances similar in all material respects to those 

presented in this petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket 

No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to 

VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see 

Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an

unmanned aircraft (UA) with the specifications described by the petitioner and carrying no 

passengers or crew, rather than a manned aircraft of significantly greater proportions, 

carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS 

operation enabled by granting an exemption to petitioner is in the public interest.

Upon review of petitioner’s reasons for requesting this exemption, It reasonably should be 

determined that:

1.)They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

2.)The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 

11112, and 11213 also apply to the situation petitioner presents; and

3.)A grant of exemption is in the public interest.

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

Petitioner should be granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) 

and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow 

the petitioner’s proposed operations and preferred alternative PIC training and 

certification.
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Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, 

speed, operating capabilities, proximity to airports and populated areas and daylight UAS 

operations to within visual line of sight (VLOS) and national security - provide more than 

adequate justification to grant the requested exemptions allowing the proposed operations 

in the NAS by petitioner Erick F. Larsen.

Respectfully,

Erick F. Larsen

262 W. Linden Ave. # C

Burbank, LA, Ca 91502

818-732-0330

ErickLarsen@Outlook.com